Ball State University
OP-21: Hazardous Waste Management

Waste minimization is any action that reduces the amount and/or toxicity of chemical wastes that must be shipped off-site for disposal as hazardous waste. The success of any waste minimization program is dependent on the conscientious participation of every individual at Ball State University. There are three methods of waste minimization: Source Elimination: Remove the source of the waste by eliminating the process or practice or by substituting another process that does not generate a waste, or generates only a secondary material that can be used as a raw material in another process. For example, some laboratory demonstrations necessitate the use of chemicals that are toxic or inherently dangerous to handle. Sometimes these demonstrations can be eliminated, reproduced by other means, or video demonstrations utilized rather than performing laboratory displays that generate hazardous wastes requiring disposal. Source Reduction: The second most desirable method of waste minimization is source reduction. This is any activity that reduces the generation of chemical hazardous waste at the source. This can be accomplished by good materials management, substitution of less hazardous materials, and good laboratory procedures. Examples include: •Implement a waste minimization policy and train all employees and students. •Re-evaluate procedures to see if a less hazardous or non-hazardous reagent could be used. •Centralize purchasing of chemicals through one person in the department or laboratory. •Date chemical containers when received so that older ones will be used first. •Keep MSDS’s for chemicals on file. •Inventory chemicals and identify their location at least once a year. •Perform laboratory experiments or demonstrations on a smaller or micro-scale. •Update inventory when chemicals are purchased or used up. •Purchase chemicals in the smallest quantities needed. •Label all chemical containers to prevent the generation of unknowns. •When considering a new procedure, obtain the chemicals needed from another lab or purchase small quantities initially. •Consider the use of pre-weighed or pre-measured reagent packets where waste generation is high. •Avoid the use of reagents containing arsenic, barium, cadmium, chromium, lead, mercury, selenium and silver. •Eliminate the use of chromic acid cleaning solutions altogether. Use non-hazardous solutions such as Alconox and Pierce RBS35. •Substitute red liquid (spirit-filled), digital, or thermocouple thermometers for mercury thermometers when it is feasible. •Consider using detergent and hot water or citrus based products for cleaning parts instead of solvents. •Use latex-based paints which are typically non-hazardous. Excess latex paints should be recycled. Excess non-latex paints must be handled by EHS as a hazardous waste. •Utilize vendors that will recycle used antifreeze. Some vendors will recycle the antifreeze on site so the antifreeze never leaves the site. Recycling: The third most desirable approach is recycling. When a waste material is used for another purpose, treated and reused in the same process, or reclaimed for another process, it is considered recycling. Examples include: •When solvent is used for cleaning purposes, use contaminated solvent for initial cleaning and fresh solvent for final cleaning. •Purchase compressed gas cylinders (including lecture bottles) only from manufacturers who will accept empty cylinders. •Return excess pesticides to the distributor. •Have a silver recovery unit installed in photography laboratories. The unit removes the silver from the fixer solution. •Do not contaminate used oil with solvents because this prevents the oil from being recycled. •Increase solvent reuse through the use of solvent redistillation. •Recirculate unused or excess chemicals within the department. •Collect metallic mercury for reclamation.

The framework for hazardous waste regulation was established in 1976 by the Federal Resource Conservation and Recovery Act (RCRA). RCRA was enacted by Congress to protect human health and the environment from improper management of hazardous waste. RCRA introduced the concept that the generator of a waste is responsible for proper waste management from “cradle-to-grave” (i.e. from the laboratory to the waste’s ultimate destruction). RCRA regulations may be found in 40 CFR Parts 260-279. At Ball State University, all chemical waste disposal is managed by the Environmental Health and Safety (EHS) Office of Facilities Planning and Management. Hazardous chemicals are not allowed to be disposed of in the drains (without EHS and Muncie Sanitary District approval), in the trash, or by evaporation. All chemical waste is required to be held in the generating location (this location is defined as a “Satellite Accumulation Area”) for subsequent pick-up and disposal by EHS and the waste disposal vendor (currently Tradebe Pollution Control Industries, Inc). See document, Invitation for Bids for Hazardous Waste Disposal and Recycling at Ball State. There are specific regulatory requirements for the individuals, laboratories, or shops, that generate and accumulate chemical waste. These individuals must properly identify and label all hazardous wastes in their workplace. They must properly store and submit requests to the EHS for disposal of chemical wastes. Finally, they must minimize the amount of waste generated and recycle whenever possible. The purpose of this document is to assist labs, shops, and the various academic Departments with this regulatory compliance. Every lab and shop on campus is subject to unannounced inspections by both the Federal Environmental Protection Agency (EPA) and the Indiana Department of Environmental Management (IDEM). Lack of compliance can result in a Notice of Violation and, potentially, fines or other penalties. The University does not maintain a centralized hazardous waste accumulation or storage building on the BSU Campus and it is therefore necessary for the Departments generating the wastes to accumulate them in accordance with the EPA/IDEM waste regulations - pending pickup for transport to off-site disposal by the BSU EHS Office.

Guiding Document, Ball State University Waste Management Guide